Launch of Disciplinary Action for Binding and Late-Submission Violations

Dezember 20, 2013 - ATB #021-13

In IE #005-13: Avoiding Binding and Late-Submission Violations, we announced a new Binding Violation Notice form. During the introductory period for this new form, we provided training and assistance to help affected agents and their staff avoid these violations.

We also tracked binding and late-submission violations during this period and found, with approximately 235,000 new-business submissions, the following number of violations:

Beginning February 1, 2014, we will use a progressive, four-step disciplinary process for these violations, which will be based on individual agent submissions (not at the agency level) and also on the number of submissions outlined below:

Disciplinary Process for Binding Violations

(based on a 12-month rolling cycle)

If the agent submits:

1.

Citizens will issue:

2.

Citizens will impose:

3.

Citizens will impose:

4.

Citizens could:

30 or fewer submissions:

A warning notice if the agent receives more than three binding violations.

A 30-day suspension if the agent receives three or more binding violations in the six months after the warning notice.

A 90-day suspension if the agent receives one binding violation in the six months after completing the 30-day suspension.

Terminate the agent’s agreement if there are any subsequent binding violations within 90 days after completing the 90-day suspension.

31 or more submissions

A warning notice if the agent receives binding violations in 10 percent or more of their submissions.

A 30-day suspension if the agent receives five or more binding violations in the six months after the warning notice.

A 90-day suspension if the agent receives three or more binding violations in six months after completing the 30-day suspension.

Terminate the agent’s agreement if there are any subsequent binding violations within 90 days after the 90-day suspension.

Disciplinary Process for Late-Submission Violations

(based on a 12-month rolling cycle)

If the agent submits:

1.

Citizens will issue:

2.

Citizens will impose:

3.

Citizens will impose:

4.

Citizens could:

30 or fewer submissions

A warning notice if the agent receives more than six late- submission violations.

A 30-day suspension if the agent receives six or more late-submission violations in the six months after the warning notice.

A 90-day suspension if the agent receives two or more late-submission violations in six months after completing the 30-day suspension.

Terminate the agent’s agreement if there are any subsequent late-submission violations within 90 days after the 90-day suspension.

31 or more submissions

A warning notice if the agent receives late-submission violations in 20 percent or more of their submissions.

A 30-day suspension if the agent receives 10 late submission violations in the six months after the warning notice.

A 90-day suspension if the agent receives six late submissions violation in six months after completing the 30-day suspension.

Terminate the agent’s agreement if there are any subsequent late submission violations within 90 days after the 90-day suspension.

Notes:

All violations incurred during the introductory period will be removed.

The disciplinary process will apply to all new submissions.

The violation counts reset after each step in the disciplinary process.

Citizens will email agents a Binding Violation Notice for each violation.

Violation Reviews

Agents who are issued a binding or late-submission violation notice are entitled to a review of the violation. The appeal for review:

Must be received in Underwriting within five business days of the date on the Binding Violation Notice

Can be uploaded into the policy file in ePAS through EDS or the agent can call Underwriting

Must include a clear statement of why the violation is being disputed

Note: Violations occur at the time that the submitted new-business application is underwritten and are based on the documentation or lack of documentation at that time. A binding violation cannot be cured through corrective action taken after the violation occurs.